Code of Conduct
Varma’s
Code of Conduct
Introduction
Varma’s success requires that its employees have a consistent understanding of the company’s tasks
and operating principles. Every employee helps uphold Varma’s most important competitive asset
– our reputation as an honest and trustworthy pension insurer.
This Code of Conduct describes Varma’s way of operating, and everyone at Varma, regardless of position
and organisational level, is expected to comply with it. We at Varma must know and understand the Code
in order to be able to act in compliance with it every day.
Employees are familiarised with the Code of Conduct when they begin working at Varma, and their
competence is maintained, for instance, through online courses. Supervisors are responsible for monitoring
compliance with the Code in their units.
The Code of Conduct was approved by Varma’s Board of Directors
on the 21st of April, 2016.
In addition to the Code of Conduct, we comply with the laws and
official regulations that are in effect at the time.
Varma’s core task is to secure pensions. Varma’s values are
productivity, customer orientation and co-operation.
Varma is politically and religiously independent.
Every Varma
employee helps
uphold our good
reputation.
We operate responsibly
Responsibility is part of Varma’s daily operations.
We actively communicate what CSR means to us and
how our responsible operations show in society. We will
continuously develop our responsible ways of operating.
For Varma, responsible operations means, first and
foremost, securing solvency and the disruptionfree implementation of pension provision. We take
environmental aspects and climate change into account
in our operations and in our investments.
Varma has signed the UN Principles for Responsible
Investment (UN PRI). The Principles for Responsible
Investment cover the company’s investment assets in their
entirety. Key criteria for selecting investees are compliance
with legislation, respect for human dignity, consideration
of social responsibility and responsibility related to
working conditions, and consideration of environmental
protection matters.
Prevention of the grey economy
and money laundering
Varma co-operates within the earnings-related pension
system to combat the grey economy. We promote
conditions for honest work and business.
In order to help identify the grey economy, we participate
in joint audits of the pension system and we hand over
information in accordance with the act on contractors’
obligations. The identification of and other guidelines
concerning the prevention of money laundering are part of
Varma’s processes.
Business transactions on
market terms
Agreements between Varma and policyholders are made
on market terms, and the same applies to Varma’s other
business transactions. We comply with good insurance
practices. Where its customers are concerned, Varma
operates independently of other insurance companies.
Varma’s business decisions must always be based on
autonomous consideration. To ensure that, Varma
conducts self-assessments of competition compliance
concerning, for example, collaboration within the
earnings-related pension sector.
Inappropriate gifts have no place
at Varma
Varma’s employees do not offer or accept gifts, payments,
hospitality or other benefits whose purpose is to influence
a decision. Gifts that are given or accepted must not call
into question the giver’s or receiver’s independence. The
value of a personal business gift cannot exceed EUR 100.
Gifts with a higher value must be approved by a supervisor.
If a Varma employee has been invited to an event
organised by a third party outside of the capital city area
or his/her business area, attendance always requires the
permission of a supervisor. In such cases, Varma will pay
the travel and accommodation costs. The organiser of the
event can, however, pay the travel costs if said organiser
is Tela, the Federation of Finnish Financial Services, or
another organisation for which Varma is a major provider
of financing.
At Varma, we do good work
At Varma, we do good work Varma’s success is based
on the competence and well-being of its staff.
Avoid conflicts of interest
Varma is a fair workplace that does not tolerate
discrimination, bullying or harassment. Inappropriate
treatment and harassment are dealt with without
exception, and the consequences range from a notice,
warning or, ultimately, termination of employment.
Every Varma employee is obligated to be loyal to the
company, and conflicts of interest must not be allowed to
influence decision-making at Varma. A conflict of interest
arises when a Varma employee who is involved in making
a decision is motivated not by Varma’s interests, but rather
by his or her own, a friend’s or a family member’s interests,
for example.
Implementation of the equality principles is monitored
regularly through personnel questionnaires and equality
surveys.
Responsibility is part of Varma’s daily operations
Conflicts of interest can be avoided by not accepting work
from another earnings-related pension company or from
Varma’s partners or customers. Do not commit to a third
party’s operations that will consume your time and require
measures to be taken during your working hours.
Varma’s senior and middle management and employees
who make investment decisions must always seek their
supervisor’s approval for board membership in companies
outside of Varma.
An exception to this rule is board membership in housing
companies, sports clubs, unions, political parties or other
similar organisations.
The abuse
of insider
information
concerns
all Varma
employees.
Abuse of insider information
is prohibited
If you are not sure
about something,
contact your
supervisor or
Varma’s chief
legal counsel.
Data protection
We process confidential information in accordance with
the Personal Data Act and good insurance practices, and
we respect insurance secrecy. Confidential information
includes personal and sensitive customer and personnel
information, as well as information related to the business
and financial situation of Varma and Varma’s client
companies.
Varma employees must not provide this information to
third parties or to colleagues whose tasks do not involve
the handling of such information.
Varma employees are obligated to keep any confidential
information they receive as part of their work confidential
also after their employment ends – this is something every
employee has committed to in their employment contract.
Varma follows insider guidelines confirmed by the Board of
Directors. The purpose of the guidelines is to promote the
public reliability of the company’s investment operations
and personnel’s knowledge of insider regulations, so that
they are not, even unintentionally, violated.
The prohibition of abuse of insider information concerns
all Varma employees. Varma has additionally appointed
individuals who must comply with insider information
guidelines in all securities trading.
The use of insider information is considered to be actions
in which someone uses non-public, important information
related to securities to their own or another person’s
advantage in securities trading. Insider information must
also not be shared with another person, unless it is a
regular part of the work or tasks being performed.
Varma’s public insider register can be accessed through
Euroclear Finland’s link.
Varma Mutual Pension Insurance Company
010 2440
Salmisaarenranta 11, Helsinki | P.O. Box 3, FI-00098 VARMA
Business ID 0533297-9
varma.fi
What to do if a problem arises
This Code of Conduct and Varma’s other guidelines are
co-ordinated by Varma’s chief legal counsel. If you have
any questions or concerns, please contact your supervisor
or Varma’s chief legal counsel.